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​What is the Phase 3 AEM plan that must be submitted to the Competent Authority?

What is the legal background?

The requirement to update your AEM plan arises from the new regulation on the monitoring and reporting of greenhouse gas emissions (called 'MRR', 'Monitoring and Reporting Regulation') which was passed on 21 June 2012 and entered into force on 1 August 2012.

How does the new AEM plan look like?

The European Commission (EC) published a new Excel version of the AEM plan template which is very similar to the current version. Most of the fields of the new AEM plan template are the same but new requirements have been added, especially regarding procedures for data management and control activities.

Can I re-use the information from the current version?

Yes. In the UK, the new version has been pre-populated with information from the current version. In Germany, it is possible to import the existing AEM plan as a XML-file into the latest FMS and to adjust it to the new requirements.

Where the Excel version is used (i.e. France, Spain, Italy, etc.), you can simply copy-paste the information from the existing AEM plan into the new template.

How can I get guidance and examples?

The UK Environment Agency published examples of completed AEM plans for both small and big emitters. Even if you do not report to the UK, you can use these examples to help you complete your AEM plan. The DEHSt also published an example of a completed AEM plan.

The EC published a guidance document to help operators understand the requirements and complete the new AEM plan template (see section 6). The examples and the guidance document are available for download below.

As a small emitter, am I required to submit a risk assessment?

No. Although the new AEM plan requires small emitters to submit a risk assessment, Article 54(3) of the MRR exempts small emitters from submitting a risk assessment when submitting the AEM plan for approval. Consequently, small emitters may choose to leave this procedure blank in the AEM plan template.

What is the deadline for the submission of the updated AEM plan?

UK: 5 September
France: 31 August
Germany: 6 November
Portugal: 14 September
Sweden: 30 August
Other Member States: please contact your Competent Authority

Please read carefully the email that was sent to you by your Competent Authority. You will find below available for download the explanatory emails that were sent by the UK, French and Germany authorities as reminders.

When will the new AEM plan become valid?

The current AEM plan based on the older template version is and will remain valid for 2012 emissions. Consequently, your 2012 emissions report will have to be based on the current AEM plan. The new AEM plan template will only concern emissions of the 2013-2020 period and will be used for the first time for the monitoring of the 2013 emissions.

Any particular recommendations?

Operators are strongly recommended to take advantage of this requirement to update their procedures so that they are consistent with current practice and existing business processes.

Also, this is an opportunity to incorporate the recommendations for improvement that may have been listed in your verification opinion statement by your verifier (see the 'improvement report' in the UK).

Does the updated AEM plan need to be verified?

No, the updated AEM plan does NOT need to be verified. It has to be submitted to the Competent Authority for approval. It is better to send any question you may have about this new requirement directly to the Competent Authority.
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